There are a number of state agencies that allow an originator license to continue operating if their renewal request was submitted during the renewal period, even if their renewal was not yet processed by the December 31st deadline. The remaining states DO NOT allow a licensee to conduct business until completion of recertification. It is important that you verify the status of a license as it may be listed as “Authorized” but with an expiration date of last year.
For a list of all states that DO NOT allow originators to conduct business during the grace period, visit the NMLS Resource Center.
If you discover that you are conducting business with an originator in a state that does NOT allow an extension beyond the published deadline for renewals, we encourage you to take the following action as it may affect your ability to be in compliance:
- Verify a license status by contacting the correlating state regulator directly.
- If you identify counterparties that are ‘Not Authorized’, cease all business until the updated status has been made.
- Give notice regarding your issue to each state agency where you have been forced to halt business.
If you are a Comergence customer, you can access additional information by visiting the help site Lender FAQ section regarding state MLO renewals. Please note, you must be logged into Comergence to access this page.